Fire Risk Assessments (FRA) - Who & How Much?

Fire Risk Assessments (FRA) are essential safety evaluations required for certain rental properties in the UK, including Houses in Multiple Occupation (HMO). The aim is to identify fire hazards, assess risks, and outline actions needed to minimize these risks, ensuring tenants' safety. This is especially critical in HMOs, where multiple tenants may live independently within a single property, increasing the complexity and potential fire risk.  We had a question about the high cost of a professional FRA and this article is based on a discussion of that issue between 2 landlord members and a letting agent. 

Why Now?

Following the tragic Grenfell Tower fire and subsequent changes in fire safety legislation, there has been increased scrutiny on fire safety standards, making comprehensive and compliant FRAs more essential than ever. As a result, HMO owners must understand the importance of an FRA, the process involved, and the associated costs.  

What is Involved in a Fire Risk Assessment?

A professional FRA assesses the fire risks associated with the property layout, usage, and fire prevention measures in place. The key steps include:

1. **Identifying Fire Hazards:** A thorough inspection of the property to spot potential fire hazards, including electrical installations, heating systems, and flammable materials.

2. **Evaluating People at Risk:** This considers tenants and visitors' safety and especially takes into account those who may have mobility issues.

3. **Assessing Existing Fire Safety Measures:** The assessor checks the current fire detection systems, escape routes, and firefighting equipment to ensure compliance with safety standards.

4. **Providing Recommendations:** The FRA concludes with detailed recommendations for improvements. This may involve installing fire doors, updating fire alarm systems, or making changes to layout and signage.

5. **Documentation and Report:** A comprehensive report is prepared outlining findings, actions required, and deadlines for remedial work to maintain compliance. 

Why Are Fire Risk Assessments Needed?

FRAs are legally required for HMOs under The Regulatory Reform (Fire Safety) Order 2005. This requirement is critical for several reasons:

- Tenant Safety: An FRA ensures that HMO landlords are taking all necessary steps to protect tenants from fire risks.

- Legal Compliance: Failing to conduct an FRA can result in heavy fines, criminal charges, or imprisonment in extreme cases.

- Landlord Liability: In the event of a fire, landlords could face liability claims if found negligent in providing a safe environment.

- Insurance Requirements: Many insurance policies for HMOs require a valid FRA. A lapse in compliance could invalidate coverage. 

Conducting an FRA: DIY vs. Outsourcing

For smaller, simpler HMO properties (e.g. 3-4 bed over two floors), some landlords opt to conduct their own FRAs using templates from resources such as the National Residential Landlords Association (NRLA). However, as properties become more complex (e.g., three or more stories or properties with internal rooms), many prefer to hire a qualified assessor.

Doing it yourself is not straightforward – do not expect to download a form, pop round to the house, tick a few boxes and then file it as a completed fire risk assessment. The templates available are a great help, but you will need to spend time thinking through the type of tenure and understanding the specific regulations applicable to that tenure as well as envisioning where fires are likely to start, whether the current infrastructure will reduce the spread of fire and also, alert your tenants in time plus you need to very carefully consider all of the escape routes in the property, what steps need to be taken to stop or reduce the spread of both fire and smoke while people evacuate and consider alternate routes should the fire affect the main escape route, where you end up when you escape and is it safe there and what restrictions may impede you – door and window locks for example.

When a house is shared by people who did not arrive as a group it will be classed as high risk – illogical as a professional let with 3 sharers has to meet the same rules as a 12-bed home for recovering (or not) addicts and alcoholics, but that is the way the rules are currently applied so you need to comply and 'high risk' requires the maximum level of detectors/alarms (every room), fire doors, closures, etc – so few will have the skills to perform their own FRA's successfully in these situations.

According to the landlord member's conversation, the decision to outsource depends on factors like:

- Complexity of the Property: Multi-story properties and those with internal rooms may require specialized attention.

- Type of Tenure: If the inhabitants are a group of friends sharing a house the risk is much lower than a group of individuals living separate lives in the same house. Unfortunately, agencies tend to take the easy path and ask whether inhabitants are on individual contracts or a joint contract which is misleading, as we see groups of friends sharing on individual contracts (as preferred by the University of Portsmouth) and we also see groups of strangers on a joint contract because the letting agent told them that was the way it was done.

- Liability and Compliance Risks: With stricter enforcement, landlords may face greater scrutiny, and outsourcing offers a level of protection as assessors are liable for their reports

Cost of an FRA

The cost of a professional FRA has risen significantly since the Grenfell tragedy and the introduction of new regulations. Here is an approximate range based on landlord feedback:

- Standard FRA Costs: £250-£600 per property, depending on property complexity and assessor reputation. One person mentioned paying around £250 due to a long-standing relationship with the assessor, but typical rates for thorough assessors can go up to £500.

- Comparisons with Other Assessments: Unlike EPCs (Energy Performance Certificates) and EICRs (Electrical Installation Condition Reports), which are relatively quicker and more standardized, FRAs are in-depth assessments tailored to each property's unique risks, requiring detailed documentation and adherence to up-to-date fire safety standards. This additional expertise contributes to the higher cost along with the lack of automation compared to other forms of certification. In the future we would hope costs will come down as AI tools remove the complexity but for the foreseeable future, expect to pay a lot more than for an EPC or an EICR.

Why FRAs Cost More Than Other Assessments

The nature of an FRA is more involved than an EPC or EICR. FRAs carry significant legal responsibility for assessors, who can be held accountable if their report fails to meet safety standards. Factors contributing to the higher cost include:

- Complexity and Customization: FRAs are tailored to individual property layouts and tenant arrangements, with no shortcuts or "assumptions" as commonly found in EPCs.

- Legislative Changes and Qualifications: Recent updates in fire safety laws demand continual professional development (CPD) for assessors, ensuring they remain knowledgeable about the latest safety standards.

- Increased Liability: Unlike EPCs or EICRs, inadequate FRA assessments can lead to criminal charges, increasing the professional liability of assessors and thereby raising costs. 

Choosing a Fire Risk Assessor

Selecting a reliable assessor is essential, as highlighted by members experience with varying levels of service. Here are some tips for choosing an assessor:

1. Check Qualifications and Experience: Look for assessors registered with recognized fire safety institutions, such as the Institution of Fire Engineers (IFE).

2. Seek Recommendations: Many landlords find assessors through word-of-mouth recommendations from other HMO owners.

3. Consider Communication and Reliability: Several bad experiences underscore the importance of communication, timeliness, and consistency in delivering reports.

4. Account for Cost and Quality: Balancing cost with diligence is key. A less expensive assessor may offer a limited service, while a thorough report may require a higher fee but provide greater peace of mind. 

Competence Or Incompetence?

Given all of the preceding comments you would maybe assume that DIY is always worse than using a professional and all professionals are alike - but sadly, as in most things to do with being a landlord, it is not that simple.

Three examples which may explain that comment:

1. I have a simple property (only 2 floors, all bedrooms open onto a hallway which leads to the front door, lounge and kitchen are separated from the escape route by a fire door, an alternate escape route exists if needed, etc). Doing my own FRA I am sure I spent considerably more time on it than any assessor would and I doubt any of them would have given a thought to the consumer unit high on the wall by the front door. In my FRA, the only risk I could not accommodate without some change in the property was a fire starting in that consumer unit which prevented the occupant of the downstairs front room from leaving their room and accessing either escape route.  Three 'professionals' were consulted along with Hampshire F&RS  - the professionals all said 'risk is too small, don't worry about it'.  However, small changes were made and I now feel my tenant is safer even in that extremely unlikely case than he or she would have been if I had just used one of the professionals and gone with their advice.

2. We had a member who wanted a 2nd opinion after getting a professional FRA organised by her letting agent.  After checking with Alice (our inhouse expert in this area), it transpired that the 'professional' had used one of Alice's FRA's from another property and simply changed the heading, removed the logos and updated the address, etc.  What made it so much worse was that it was an old FRA and inappropriate for that property because of changes to regulations since it had been written.

3. Another member had an FRA organised by her letting agent, and this was one of the better agents in the city, and she was concerned about some of the recommendations in the report.  Alice reviewed the property and produced a new FRA which was cheaper than the agent provided one and corrected the original which recommended removing smoke alarms/detectors from the individual rooms and other changes inline with recommendations for an accommodation block but wholly inappropriate for that property and, had they been implemented, would have resulted in significant cost and much increased risk in the event of a fire.

Recommendation?  Find a competent assessor.

How do you find a competent assessor? We would suggest word of mouth and personal recommendation as qualifications and accreditations do not appear to correlate with competence in the manner one would hope.

Final Thoughts

A key point made by one member in the discussion was, "that the new regulations specifically put the liability on the responsible person for ensuring any assessor is "competent" and perhaps it is not the skills or lack thereof, that is an issue for DIY FRAs (where needed), it's the proving of competency in the event of a fire which is the major problem? If you can't prove in a court that you were competent (via certification, training, CPD, etc), responsible persons/landlords will likely have an issue"

The requirement for a professional Fire Risk Assessment reflects an increasing commitment to tenant safety in the UK rental sector. By understanding the purpose, process, and costs involved, landlords can make informed decisions that meet legal obligations and protect both their tenants and investments. Given the increased liabilities and complexities in fire safety regulations, it is advisable for landlords, especially those with more complex HMO properties, to consider outsourcing FRAs to qualified assessors.

If you need further guidance on FRA requirements or a checklist for self-assessment, resources like the NRLA templates or official fire safety guides from local authorities can provide additional insights.